Privacy Policy

CONFIDENTIALITY AND PERSONAL DATA PROTECTION POLICY

In order to carry out its activities, Continental Hotels S.A., as data controller, processes personal data of certain categories of natural persons. This may include personal data of users of this Site, users who interact with the pages created by Continental Hotels S.A. on social networks, our customers, our partners/potential contractual partners or their employees, representatives or collaborators whose data is provided to us for processing, employees of Continental Hotels S.A. or candidates wishing to fill positions within Continental Hotels S.A..

According to the Regulation 679 of 27 April 2016 on the processing and free transfer of personal data, and repealing Directive 95/46/EC (“GDPR”), personal data is any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier.

 

1. Purposes, grounds and categories of personal data

The data processed by Continental Hotels S.A. may be used for purposes such as:

1.1 Administration and maintenance of this Site, which also involves the use of cookies, so as to ensure quick and easy interactions between users and the Site (legal basis: art. 6 para. (1) lit. a) and f) of the GDPR, respectively your consent and the proper interest of Continental Hotels S.A., as the case may be).

For more details about the use of cookies by Continental Hotels S.A., please refer to our Cookie Policy.

1.2 Registration and implementation of your request for reservation and provision of tourist and catering services (legal basis: art. 6 para. (1) lit. b), c) of the GDPR, i.e. the implementation of a contract or the performance of necessary steps at the request of the data subject prior to the conclusion of the contract or the fulfilment of legal obligations of Continental Hotels S.A. as the case may be). When you choose to book through the Site, Continental Hotels S.A. processes the following categories of data: name, surname, gender, e-mail address, telephone number, country of residence, date of arrival, date of departure, bank account, data on minor-accompanying persons (age), name, surname and age of the adult-accompanying person (optional);

To manage your booking, Continental Hotels S.A. may also process the following categories of data: data on your companion(s) for determining the occupancy of the reserved room, details of your correspondence, requests, complaints, any other data or information related to your interaction with us.

In order to fill in the Arrival and Departure Form (in accordance with the Decision 237/2001 for the approval of the rules of access, registration and protection of tourists), Continental Hotels S.A. will process the following categories of data: name and surname, date of birth, place of birth, citizenship, residence (city, street, number, country), date of arrival, date of departure, purpose of travel, ID details, signature, email address (optional).

1.3 Rental of space, organisation of private or corporate events (legal basis: art. 6 para. (1) lit. b) of the GDPR, i.e. the implementation of a contract or the performance of necessary steps at the request of the data subject prior to the conclusion of the contract);

1.4 Carrying out recruitment operations for purposes such as: assessing your application, skills, qualifications and interests in relation to the position for which you have applied and for which you have been contacted, organising and conducting interviews and selecting and recruiting you, facilitating access to occupational health services and carrying out general checks (legal basis: art. 6 para. (1) lit. b) and lit. f) of the GDPR, i.e. carrying out pre-contractual arrangements, concluding and executing the employment contract with you or fulfilling our legitimate interests, as the case may be).

As for your application, it is necessary to process the data in the application. This data will usually include your name, surname, contact details (telephone number, e-mail address), professional experience, education and any other information you choose to include in your CV or other documents we may request from you. We will also process personal data such as: professional preferences, details of your experience and education not included in your CV, your salary expectations.

As for the employment process, we may ask you for additional documents (such as school transcripts, diplomas, certificates, licenses, professional qualifications, etc.), which will also contain personal data.

To evaluate your application, in addition to the information already submitted, we may also access your publicly available social networking profiles (such as LinkedIn). As matters relating to your private life do not concern us, we will not consult or take into account those profiles or profile information that are clearly intended to remain private and do not have a professional component.

1.5 Employment relationships for the performance of the employment contracts, the fulfilment of legal obligations and/or the fulfilment of a legitimate interest (legal basis: art. 6 para. (1) lit. b), c) and f) of the GDPR, as applicable). In certain specific cases, Continental Hotels S.A. processes employee data on the basis of their consent (legal basis: art. 6 para.) The way in which Continental Hotels S.A. processes the personal data of its employees is detailed in the information note provided to them.

1.6 Organizing and carrying out advertising campaigns by Continental Hotels S.A. and marketing and promotion activities (such as sending newsletters, promotional materials, commercial offers, marketing communications), asking for your opinion on the services we have offered you (through the customer satisfaction questionnaires), as well as carrying out market, product and analysis studies of our services (legal basis: art. 6 para. (1) lit. a), lit. f) of the GDPR, i.e. your consent and the realization of the legitimate interests of Continental Hotels S.A., where applicable, including under Law 506/2004 on the processing of personal data and the protection of privacy in the electronic communications).

By carrying out direct marketing activities, we may keep you informed about our services and campaigns in accordance with the applicable laws. You can unsubscribe from the newsletter service at any time and free of charge by ticking the “Unsubscribe” option in the newsletter.

1.7 Ensuring the security of property, persons and premises by means of video surveillance (legal basis: art. 6 para. (1) lit. c) and f) of the GDPR, i.e. the fulfilment of a legal obligation and the legitimate interest of Continental Hotels S.A.). For this purpose, Continental Hotels S.A. processes your personal data, i.e. your image captured by the video surveillance equipment, your first and last name and vehicle registration number, if applicable.

1.8 Communication with our collaborators and contractual partners (legal basis: art. 6 para. (1) lit. b) and f) of the GDPR, i.e. the conclusion and execution of the contract or the legitimate interest of Continental Hotels S.A., as the case may be). For this purpose, Continental Hotels S.A. processes your name, surname, position and/or capacity held and the organisation you represent, your holographic or electronic signature, and your ID details.

If any contractual partner of Continental Hotels S.A. discloses the personal data of its designated contact persons, legal or contractual representatives, collaborators, employees and/or other natural persons to Continental Hotels S.A. for or in connection with the conclusion and/or performance of a contract, given that Continental Hotels S.A. cannot directly inform these categories of persons, the contractual partner of Continental Hotels S.A. is obliged to inform these persons about the processing of personal data by Continental Hotels S.A. The contractual partner of Continental Hotels S.A. will take steps to ensure that this disclosure is made in accordance with any applicable requirements, including those relating to informing and obtaining the consent of the data subjects, if applicable, so that Continental Hotels S.A. may process the personal data for the purposes laid down in the contract without further formalities.

1.9 Handling your requests, questions or complaints (legal basis: art. 6 para. (1) lit. b) and f) of the GDPR, i.e. the performance of a contract or taking the necessary steps at the request of the data subject prior to the conclusion of the contract and the legitimate interest of Continental Hotels S.A., as the case may be). For this purpose, Continental Hotels S.A. processes the name, surname, contact details and opinions provided by you.

 

2. How do we get the data?

Continental Hotels S.A. can obtain the data:

  • directly from you, for example, when you use the services of Continental Hotels S.A., when you contact us through various channels or ask us for offers or information about our services, when you visit our Site or pages on social networks or when you apply for available positions within Continental Hotels S.A.;
  • from other sources, e.g. travel agencies, booking sites (e.g. Booking.com), public authorities (e.g. in case of court requests or judicial investigations).

 

3. Recipients of your personal data. Data transfer

Personal data may be disclosed by Continental Hotels S.A. to the following categories of recipients:

  • when exercising your rights under the GDPR;
  • Continental Hotels S.A.’s contractual partners (such as courier companies, suppliers, collaborators, subcontractors, consultants and technical experts, etc.) for the conclusion and execution of contracts;
  • public authorities and institutions, based on the legal obligations we have under the applicable laws;
  • to the external auditors of Continental Hotels S.A., for the fulfilment of audit obligations;
  • lawyers, tax/business consultants, to represent us in the event of litigation or for advice;
  • to bailiffs, for contractual communications or for the enforcement of contracts or eventual court decisions;
  • debt recovery firms;
  • in the event that Continental Hotels S.A. undergoes a sale or reorganization process, we will provide your data to the acquiring entity and/or its advisors or to the entity resulting from the reorganization process.

In order to achieve some of the above-mentioned purposes, it is possible that certain categories of personal data may be transferred outside Romania. The data may be transferred to countries within the European Economic Area (“EEA”) as well as outside the EEA.

For transfers outside the EEA, the company will base its transfer on the requirements of the GDPR and under the standard data protection clauses adopted by the European Commission, to ensure the necessary level of security and confidentiality or on other guarantees recognised by law.

 

4. Duration of processing of personal data

Continental Hotels S.A. processes your personal data for as long as necessary to fulfil the processing purposes for which they were collected, and subsequently, if necessary, to comply with the legal requirements applicable to our field of activity.

In the case of CV that you send us, it will be kept for 2 years after the end of the recruitment process, only if you have expressed your consent to this.

It is possible that Continental Hotels S.A. will anonymize the data, thus removing any personal data, after the legal archiving deadlines have expired.

 

5. Your rights

With regard to the personal data processing, you have the right to access information and data, the right to correct the data, the right to erase the data, the right to restrict the data, the right to transfer the data, the right of objection, the right not to be subject to an individual decision, the right to address the National Supervisory Authority for Personal Data Processing (according to the information available on www.dataprotection.ro) or the courts.

To exercise these rights, you may send a request to Continental Hotels S.A. to the attention of the Data Protection Officer dpo@continentalhotels.ro or by post/mail to our mailing address mentioned above.

This Policy is updated periodically; each time we make a change, we will post it on our website https://continentalhotels.ro/.

Last update: July 2023